DC Plan Termination and Post PPA (Cycle 3) Restatement

If a plan is terminating effective 8/31/2021, does the pre-approved document still need to be restated for Cycle 3?  I know that it would need to be amended for CARES/SECURE, but is the restatement required?

I believe as long as the assets are distributed before the restatement deadline (July 31, 2022) the restatement is not required as long as the appropriate interim amendments are in place, as you alluded to.

Gilmore, depending on the vendor, you may get a different response from different document providers, as I experienced with my various communications with them. I for one believe in full restatement but that is me.

I am curious what others will say.

Personally, I think a restatement is, or should be, so easy that it's not worth thinking about; just do it and move on.  If the concern is charging a "large" restatement fee just as the plan is terminating, we changed to an annual doc maintenance fee two cycles back and it eliminates a lot of this consternation and wasted thought/time over these issues.

Thanks for the input!

I am in total agreement that the full restatement is the best way to go, especially if the termination is not submitted to the IRS, but it may not be the only option.  I think the full restatement was especially important when interim amendment language was captured in the new version of the document.  This time around there are at least three interim amendments that are not part of the pre-approved language, at least with our document vendor.